'Pursuant to Article 10 (Applicable Procedural Rules) of the Terms of Reference, the Arbitral Tribunal, having consulted with the parties, issues the following procedural rules to apply to these arbitration proceedings:

1. Written submissions

1.1. The parties shall submit their allegations of facts in a detailed, specified and comprehensive manner, and shall respond specifically to all allegations of facts made by the other party.

1.2. In all written submissions to the Arbitral Tribunal, the parties shall divide their factual allegations into consecutively numbered paragraphs.

1.3. Following each factual allegation, the parties shall, whenever possible, identify the evidence adduced or to be adduced in support of that allegation.

1.4. Each party shall file with the chairman of the Arbitral Tribunal one additional copy of its written pre-hearing submissions, together with documents and witness statements (as herein provided).

. . . . . . . . .

4. Witnesses

4.1. Any person may present evidence as a witness, including a party or a party's officer, employee or other representative.

4.2. For each witness, a written and signed witness statement shall be submitted to the Arbitral Tribunal, unless the parties cannot obtain such a statement from a witness for a legitimate reason which such party will explain to the Arbitral Tribunal. The Arbitral Tribunal shall fix the date for each party to submit its witness statements or indicate the reasons for which a statement cannot be filed for a particular witness. The witness statements shall be numbered discretely from other documents and properly identified as such (e.g. "CWS" (Claimant's witness statements) followed by the applicable number, respectively "RWS" (Respondent's witness statements) followed by the applicable number.

4.3. Each party shall be responsible for summoning its own witnesses to the applicable hearing, except when the other party has waived cross-examination of a witness and the Arbitral Tribunal does not direct his or her appearance.

4.4. Each party shall advance the costs of appearance of its own witnesses. The Arbitral Tribunal will decide upon the appropriate allocation of such costs in its final award.

4.5. At the request of a party, the Arbitral Tribunal may summon a witness to appear.

4.6 If a witness fails to appear when first summoned to a hearing, the Arbitral Tribunal may summon the witness to appear a second time if satisfied that there was a valid reason for the first failure to appear and that the testimony of the witness is relevant.

4.7. The Arbitral Tribunal may consider the witness statement of a witness who provides a valid reason for failing to appear when summoned to a hearing, having regard to all the surrounding circumstances. The Arbitral Tribunal shall not consider the witness statement of a witness who fails to appear and does not provide a valid reason.

4.8. If necessary, the Arbitral Tribunal shall make a procedural order prior to the first hearing with respect to the language in which the witnesses will testify and the requirements for the translation of any testimony in a language other than English or French.

4.9. At the hearings, the examination of each witness shall proceed as follows:

a) the party summoning the witness may briefly examine the witness, if it is considered necessary to complete the witness statement;

b) the adverse party may then cross-examine the witness;

c) the party summoning the witness may then re-examine the witness with respect to any matters or issues arising out of the cross-examination; and

d) the Arbitral Tribunal may examine the witness at any time, either before, during or after examination by one of the parties.

4.10. The Arbitral Tribunal shall, at all times, have complete control over the procedure for hearing a witness. The Arbitral Tribunal may in its discretion:

a) refuse to hear a witness if it considers that the facts with respect to which the witness will testify are either proven by other evidence or are irrelevant;

b) limit or refuse the right of a party to examine a witness when it appears that a question has been addressed by other evidence or is irrelevant; or

c) direct that a witness be recalled for further examination at any time.

4.11. It shall not be improper for counsel to meet witnesses and potential witnesses to establish the facts, prepare the witness statements, and prepare the examinations.

5. Experts

5.1. Each party may retain and submit the evidence of one or more experts to the Arbitral Tribunal. The procedural rules set out in the above Article 4 shall apply by analogy to the evidence of experts.

5.2. The Arbitral Tribunal may, on its own initiative or at the request of a party, appoint one or more experts. The Arbitral Tribunal shall consult with the parties on the selection, terms of reference and conclusions of any such expert. The Arbitral Tribunal may, on its own initiative or at the request of any party, take oral evidence of such expert(s). The procedural rules set out in the above Article 4 shall apply by analogy.

6. Time limits

6.1. The Arbitral Tribunal shall set the time limits for each step in this arbitration.

6.2. The Chairman of the Arbitral Tribunal may extend the time limits as necessary or appropriate. The Chairman shall only grant the extension of a time limit as an exception and provided that the request for an extension is made without undue delay and, in principle, before the time limit to be extended has lapsed.'